We are hearing some suggestions from auditors and examiners to have a formal employee training program. We do employee training and retain documentation, attendance sheets, etc. I am just curious as to how they like to see these things set up? I am not sure what they are looking for?

If they're making suggestions, ask them specifically what they mean. Ask them where your current training is causing concern, and what steps you need to shore it up.

Absolutely---ask. What are their concerns? Were certain training gaps identified? Don't try to guess, it just never serves us well in the long run.

While I agree you should ask for more specifics.....
One of the things they wanted us to do was to PLAN all the training. I just sent out a calendar at the first of the year with all required training dates where possible, and with proposed training descriptions-the dates of which would be announced.

I liked using my audit calendar to plan training. If you're doing a Reg B audit in December, do Reg B training 2 or 3 months before. When you do your audit, were there any problems before the audit that were not there after the audit? That means the training was effective.

I would suggest documenting specific training expectations such as:

* New employees will receive X training within the first 30 days, and will prove their understanding by . . .
* Existing employees will receive training on the following sub-topics annually; (e.g. identifying suspicious activity, validating identities of callers, location of CRA file, etc.)
* Employee knowledge of X will be assessed through quarterly management quizzes. Unacceptable scores of X or below will necessitate employee review of procedures within 30 days.
* Employees will certify their understanding of X by signing the X policy annually.
* Training procedures will be evaluated through . . .
* Dept manager will stay up to date on emerging trends and issues by subscribing to . . . /attending . . .

Adding those types of details moves training from ad hoc to a formal, repeatable, and measurable process. It allows examiners to clearly determine if employees got the training management intended for them. If you just retain sign-in sheets and agendas, there is no way for examiners to know 1) if it was enough training, or 2) if it was the right training. Identifying expectations within policy allows them to do that.

We have a formal training program with job specific curriculum assigned to employees to be completed each year. Training is monitored, tested, results are maintained for review by examiners. we have internet based compliance training, but we also do a fair amount of in-house training either in person or via WebEx. This is all assigned and records are maintained.